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All About Costs A Post-Award Primer

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Title: All About Costs A Post-Award Primer


1
All About Costs A Post-Award Primer
NIH Regional Seminar Chicago, IL June 2008
2
Discussion Topics
  • Cost Principles
  • Administrative Standards
  • Matching or Cost Sharing
  • Salary Rate Limitation
  • Award Restrictions
  • Responsibilities
  • Accounting Basics
  • Monitoring Basics
  • Audit Requirements
  • Subrecipient Monitoring
  • NIH Financial Reporting Basics
  • Closeout

3
Federal Requirements
4
Cost Principles
  • OMB Circular A-21 - Educational Institutions
  • OMB Circular A-122 Non-Profits
  • OMB Circular A-87 State/Local Governments
  • 45 CFR Part 74, Appendix E - Hospitals
  • 48 CFR Subpart 31.2 (FAR) For-profits
  • Foreign institutions comply with the applicable
    cost principles depending on the type of
    organization

http//www.whitehouse.gov/omb/circulars/ http//ww
w.gpoaccess.gov/cfr/index.html
5
OMB Circular A-21/A-122 Cost Principles
  • Establishes principles for determining costs
    applicable to grants, contracts, and other
    agreements
  • Direct costs
  • FA/indirect costs
  • Selected items of cost
  • allowable/unallowable costs
  • time and effort reporting

6
Administrative Standards
  • OMB Circular A-110
  • 2 CFR Part 215 (formerly at 45 CFR Part 74)
    Uniform Administrative Requirements for Grants
    and Agreements with Universities, Hospitals and
    Other Non-Profit Organizations (domestic and
    foreign)

7
OMB Circular A-110 Administrative Requirements
  • Prescribes
  • Preaward requirements
  • Postaward requirements
  • Also requirements for
  • Payment
  • Matching or Cost sharing
  • Accounting for program income
  • Revision of budget and program plans
  • Non-Federal audits
  • Allowable costs
  • Financial management systems standards
  • Property standards
  • Procurement standards
  • Reports and records

8
Audit Requirements
  • In general, OMB Circular A-133 requires a State
    government, local government, or non-profit
    organization (including institutions of higher
    education) that expends 500,000 or more per year
    under Federal grants, cooperative agreements,
    and/or procurement contracts to have an annual
    audit by a public accountant or a Federal, State,
    or local government audit organization.
  • Foreign and Commercial (for-profit) organizations
    are subject to audit provisions contained in 45
    CFR 74.26 (d) and the NIH Grants Policy Statement

9
Summary of Applicable Regulations Summary of Applicable Regulations Summary of Applicable Regulations Summary of Applicable Regulations
Grantee Type Admin Requirements Cost Principles Audit Requirements
State Local Governments A-102 (45 CFR Part 92) A-87 (2 CFR Part 225) A-133 __________________ 45 CFR Part 74.26(d)
Colleges Universities A-110 (2 CFR Part 215 formerly at 45 CFR Part 74) A-21 (2 CFR Part 220) A-133 __________________ 45 CFR Part 74.26(d)
Non-Profits A-110 (2 CFR Part 215 formerly at 45 CFR Part 74) A-122 (2 CFR Part 220) A-133 __________________ 45 CFR Part 74.26(d)
Hospitals A-110 (2 CFR Part 215 formerly at 45 CFR Part 74) 45 CFR Part 74, App E A-133 __________________ 45 CFR Part 74.26(d)
For-Profits A-110 (2 CFR Part 215 formerly at 45 CFR Part 74) FAR 31.2 (48 CFR Subpart 31.2) A-133 __________________ 45 CFR Part 74.26(d)
Foreign A-110 (2 CFR Part 215 formerly at 45 CFR Part 74) As stated above for your grantee type NIH GPS, uses 45 CFR Part 74.26(d)
10
Grant Award Basics
NOTICE OF AWARD
CENTER GRANT
Issue Date06/24/2007 Department of Health and
Human Services National Institutes Of Health
11
Read the Notice of Award
  • Special Terms and Conditions Section IV
  • Other Terms of Award Section III
  • 45 CFR Part 74 or 92 - HHS rules and requirements
    that govern the administration of grants
  • NIH Grants Policy Statement policy requirements
    that serve as the terms and conditions of NIH
    awards (latest version 12/01/03)
  • Program legislation
  • Program regulations
  • 42 CFR Part 52 - Grants for Research Projects

12
Award Restrictions
  • Only applied to a particular grant for cause
  • Shown on the Notice of Award (NoA) Letter after
    Section III
  • Funds usually are not restricted in the Payment
    Management System
  • Restricted funds must be tracked by grantee to
    ensure compliance
  • EXAMPLE of Award Restriction No funds may be
    expended for equipment without the written prior
    approval of the NIH awarding component.

13
Who is Responsible for Post-Award Financial
Management?
  • A. The Principal Investigator
  • B. The Departmental Administrator
  • C. The Department Chair
  • D. The Institution

14
Accounting Basics
15
Accounting
  • Requires that
  • Separate account is established for each project
  • Program Income is identified and accounted for by
    project
  • Program Income is used in accordance with the
    appropriate alternative, i.e.,
  • Additive
  • Deductive
  • Combination
  • Matching

16
Accounting (cont.)
  • Requires that
  • Expenses are charged in accordance with
  • NoA Terms and Conditions
  • NIH Grants Policy Statement
  • Salary Rate Limitation
  • Cost Accounting Standards
  • OMB Circulars
  • ALL expenses are appropriately documented

17
Matching or Cost Sharing
  • Matching or Cost sharing must be accounted for
  • Cost Sharing is NOT required as a condition of
    applying for or receiving unsolicited NIH awards
  • Matching only applies to a few NIH solicited
    programs

18
Salary Cap
  • Restricts the amount of direct salary under a
    grant or contract to Executive Level I of the
    Federal Executive Pay Scale
  • Executive Level I increase effective January 1,
    2008

191,300
186,600
January 15, 2008 NIH Guide Notice
http//grants.nih.gov/grants/guide/notice-files/NO
T-OD-08-035.html
19
Monitoring Basics
20
Monitoring
  • Requires that
  • Actual expenses are periodically compared with
    budget
  • Actual expenses are accurate, i.e., reasonable,
    allocable, allowable and consistently charged
  • Mischarges are corrected in a timely manner (cost
    transfers)
  • Prior approvals are obtained when required
  • Subrecipient expenses are monitored - (pass
    through entitys Grantees responsibility)

21
Budget vs. Actual
  • Actual expenses should be compared at least
    monthly to the budget to ensure
  • Total funds on the grant have not been exceeded
  • Total funds are used appropriately
  • Total funds for any cost category have not been
    exceeded if restricted on the NoA

22
Accurate Charges
  • Actual expenses should be reviewed at least
    monthly to ensure they are accurate and
  • Reasonable
  • Allocable
  • Allowable
  • Consistently applied

23
What does reasonable mean?
  • A cost may be considered reasonable if the nature
    of the goods or services acquired reflect the
    action that a prudent person would have taken
    under the circumstances prevailing at the time
    the decision to incur the cost was made.

24
Example Reasonable?
  • Dr. Grant needed a specialized microscope for his
    research supported by an NIH grant from the
    National Cancer Institute. When deciding on the
    model that would best suit his needs, he received
    several price quotes on various models that were
    all within the same general price range.
    However, one microscope in particular appealed to
    him it met all of the necessary specifications
    plus many additional features. Although it was
    about 3,500 more than the others, he ordered it.

25
What does allocable mean?
  • A cost is allocable to a specific grant if
  • it is incurred solely in order to advance work
    under the grant
  • if it benefits both the grant and other work of
    the institution
  • if is necessary to the overall operation of the
    organization
  • and is deemed assignable, at least in part, to
    the grant.

26
Example Allocable?
  • When Dr. Grants microscope finally arrived, he
    found that equipment funds for his National
    Cancer Institute grant were fully expended.
    Since the microscope was for use on an NIH grant,
    he decided to charge the cost to another one of
    his NIH grants that was funded by the National
    Eye Institute.

27
What does allowable mean?
  • A cost is allowable if it is reasonable,
    allocable and conforms to the cost principles and
    the sponsored agreement AND is not prohibited by
    law or regulation
  • Conformance with limitations and exclusions as
    contained in the terms and conditions of award
    including the cost principlesvaries by type of
    activity, type of recipient, and other
    characteristics of individual awards.

28
Example Allowable?
  • Dr. Grant decided to host a very important
    Departmental meeting at her home and serve beer
    and pizza hoping that everyone would attend. The
    purpose of the meeting was to discuss changes in
    NIH grants policy, which affected the work of the
    entire Department. Therefore, she decided to
    charge the cost of the beer and pizza to her
    grant, especially since she was providing the use
    of her home.

29
What does consistently applied mean?
  • Grantees must be consistent in assigning costs to
    cost objectives. Although costs may be charged as
    either direct costs or FA costs, depending on
    their identifiable benefit to a particular
    project or program, they must be treated
    consistently for all work of the organization
    under similar circumstances, regardless of the
    source of funding, so as to avoid duplicate
    charges.

30
Example Consistently Applied?
  • Dr. Grants lab was running low on office
    supplies and postage stamps. Since she couldnt
    wait any longer for her institution to provide
    the supplies, she purchased them and charged them
    to her NIH grant account.

31
Cost Transfers
  • Used to correct
  • Erroneous charges
  • Unreasonable charges
  • Unallocable charges
  • Unallowable charges
  • Inconsistently applied charges
  • Must be well documented
  • Must be made within 90 days from the time error
    was discovered

32
Selected Items Requiring Prior Approval
  • Change in scope or objective of a project
  • Change in Scope is a change in direction, type of
    training, or other area that constitutes a
    significant change from the aims, objectives, or
    purpose of the originally approved project

33
Change in Scope
  • Actions likely to be considered a change in
    scope
  • Change in the specific aims approved at the time
    of award
  • Substitution of one animal model for another
  • Any change from the approved use of animals or
    human subjects
  • Shifting research emphasis from one disease area
    to another
  • A clinical hold by FDA under a study involving an
    IND or an IDE
  • Applying a new technology i.e., changing assays
    from
  • those approved to a different type of assay
  • Transferring the performance of substantive
    programmatic work
  • to a third party through a consortium agreement,
    by contract, or any other means

34
Change in Scope (cont.)
  • Actions likely to be considered a change in
    scope
  • Change in key personnel named in the NoA
  • Significant rebudgeting resulting from a change
    in scope
  • Incurrence of patient care costs not previously
    approved by NIH
  • Rebudgeting funds into or out of the patient care
    category
  • Purchase of a unit of equipment exceeding 25,000
    due to a change in scope

35
Selected Items Requiring Prior Approval
  • Change in PI or Other Key personnel specifically
    named in the Notice of Award (NoA)
  • Must notify NIH if the PI or other key personnel
    named in the NoA will
  • withdraw from the project entirely
  • be absent 3 months or more
  • reduce time devoted to the project by 25 or more
  • Must request approval of a substitute PI or other
    key personnel named in the NoA
  • Note Must notify the awarding office GMO in
    writing if grantee wishes to terminate the award
    because it cannot make suitable alternate
    arrangements

36
Selected Items Requiring Prior Approval (cont.)
  • Required for
  • Preaward costs gt 90 days prior to the effective
    date of the initial budget period of a project
    period for a new or competing continuation award
  • Deviation from award terms and conditions
  • Activities disapproved or restricted as a
    condition of the award
  • Change of grantee organization

37
Selected Items Requiring Prior Approval (cont.)
  • Required for
  • Adding a foreign component
  • Rebudgeting into alteration renovation (AR)
    costs that meets the definition of change in
    scope
  • Retention of research grant funds when K-award is
    made
  • Second No-cost extension or extension greater
    than 12 months
  • Transferring of funds from trainee costs
    (stipends or tuition/fees and health insurance)

38
Selected Items Requiring Prior Approval (cont.)
  • CARRYOVER OF UNOBLIGATED FUNDS
  • Check Section III of the NoA to determine if the
    grantee has carryover authority
  • If prior approval is required to carryover funds,
    the following term will appear on the NoA
  • Carryover of an unobligated balance into the
    next budget period requires Grants Management
    Officer prior approval.

39
Prior Approval Process
  • All requests for NIH awarding office prior
    approval must be
  • made in writing (includes submissions by e-mail)
  • sent to the designated GMO shown on the NoA
  • made no later than 30 days before the proposed
    change
  • must be signed by the Authorized Organizational
    Representative
  • Note Approval must be obtained from the GMO
    through a revised NoA or letter

40
  • What authorities do grantees have?

41
No Cost Extensions
  • Without prior approval, grantees may extend the
    final budget
  • period of the project period one time up to 12
    months if
  • No additional funds are required
  • Scope will not change, and
  • Any one of the following applies
  • Additional time beyond the established expiration
    date is required to ensure adequate completion of
    the originally approved project
  • Continuity of NIH grant support is required while
    a competing continuation application is under
    review
  • The extension is necessary to permit an orderly
    phase out of a project
  • Note having unexpended funds is not an
    appropriate justification for extending a project

42
Rebudgeting
  • Effective with the NIH GPS (3/01), the prior
    approval for significant rebudgeting has been
    eliminated unless it is an indication of a change
    in scope of the approved project
  • Significant rebudgeting occurs when expenditures
    in a single direct cost budget category deviate
    (increase or decrease) more than 25 of the total
    costs awarded.

43
Rebudgeting
  • Grantees may rebudget between direct and FA
    costs (in either direction) without NIH prior
    approval, provided there is no change in scope of
    the approved project
  • According to A-21, rebudgeting between direct and
    FA is not allowed to cover increases in
    negotiated FA rates

44
NIH Financial Reporting Basics
45
Financial Reporting
  • Financial Status Report (FSR) must be submitted
    through eRA Commons
  • Timely, i.e., report submission must adhere to
    the following deadlines
  • Non-SNAP must be submitted within 90 days
    following the end of each budget period
  • SNAP must be submitted within 90 days following
    the end of the project period
  • NOTE NoA will specify if more frequent or other
    financial reporting is required

46
Financial Reporting
  • FSRs should be submitted accurately
  • Reported expenses and program income must agree
    with institutional accounting records
  • Routine Revisions to correct FSRs are not
    appropriate
  • See NIH Guide, July 27, 2007, NIH Requiring
    Mandatory Use of the Electronic Financial Status
    Report System in the eRA Commons Beginning
    October 1, 2007 http//grants.nih.gov/grants/guide
    /notice-files/NOT-OD-07-078.html
  • See NIH Guide, February 22, 2001, FINANCIAL
    STATUS REPORTS REMINDER AND INFORMATION ON
    TIMELINESS AND ACCURACY REQUIREMENTS
  • http//grants.nih.gov/grants/guide/notice-files/N
    OT-OD-01-021.html

47
Closeout Final Reports
Reminder
  • Failure to submit timely final reports may affect
    future funding to the organization
  • Final Financial Status Report (FSR)
  • Final Invention Statement and Certification
  • Final Progress Report
  • April 2, 2008, NIH Announces New Centralized
    Processing Center for Receipt of Grant Closeout
    Documents and Reminds Grantees of Required
    Closeout Reports for NIH Assistance Awards
  • http//grants.nih.gov/grants/guide/notice-files/N
    OT-OD-08-061.html
  • June 17,2005, NIH Announces New Closeout Feature
    in the eRA Commons and Reminds Grantees of
    Required Closeout Reports for NIH Assistance
    Awards
  • http//grants2.nih.gov/grants/guide/notice
    -files/NOT-OD-05-051.html

48
A Rule of Thumb
  • Whenever you are contemplating significant
    postaward changes and you are uncertain about the
    need for prior approval, consult in advance with
  • Your Office for Sponsored Research/Projects
  • NIH awarding component Grants Management
    Officer/Specialist

49
Questions?
  • Division of Grants Compliance and Oversight
  • Office of Policy for Extramural Research
    Administration
  • National Institutes of Health
  • GrantsCompliance_at_nih.gov
  • Diane Dean, Director
  • dd12a_at_nih.gov
  • 301-435-0949
  • Jeannette Gordon, Assistant Grants Compliance
    Officer
  • jg82s_at_nih.gov
  • 301-451-4224
  • Kathy Hancock, Assistant Grants Compliance
    Officer
  • kh47d_at_nih.gov
  • 301-435-1962
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